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Understanding the IRS Emphasis on BSA Filings in Tax Crime Investigations

24 February, 2024

The Internal Revenue Service (IRS) places significant emphasis on the role of Bank Secrecy Act (BSA) filings in supporting the work of its Criminal Investigations (CI) division. Their recent report indicates that an impressive 88%

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Are Trusts Required to Report under the Corporate Transparency Act (CTA)?

10 February, 2024

Generally, the answer is no. Starting January 1, 2024, the Corporate Transparency Act (CTA) will require most U.S. corporations, LLCs, and other legal entities formed through state filings or foreign entities registered to do business

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Is First-Time Abatement Applicable In International Penalty Cases?

26 January, 2024

The Internal Revenue Service (IRS) issued a memorandum from John E. Hinding, the Director of Specialized Examination Programs & Referrals, regarding penalty abatements for Forms 5471 and 5472. The memo was addressed to IRS Independent

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National Taxpayer Advocate calls IRS Penalties Draconian and Inefficient

19 January, 2024

National Taxpayer Advocate Erin Collins recently issued her 2023 Annual Report to Congress. By law, the Advocate’s report is required to identify the 10 most serious problems taxpayers are experiencing in their dealings with the IRS

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Crypto is not = Cash currency for IRS reporting

17 January, 2024

The IRS released Announcement 2024-4, providing transitional guidance under section 6050I with respect to reporting transactions involving the receipt of digital currency. Generally, when receiving more than $10,000, IRS reporting is required. The announcement clarifies that, at

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Interesting 2023 Foreign Account Cases

17 January, 2024

Foreign Account/FBAR confusion: In Kurotaki v. United States, 132 AFTR2d 2023-6138, a Hawaii federal district court determined that a U.S. green card holder who lived in Japan and spoke no English did not willfully fail

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Fantastic Recommendations for Form 3520

15 January, 2024

The American Institute of CPAs (AICPA) recently sent excellent recommendations to the Internal Revenue Service (IRS) against the IRS’ systemic assessment of penalties for late-filed Forms 3520, Annual Return To Report Transactions With Foreign Trusts

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The New IRS ERC Voluntary Disclosure Program

10 January, 2024

The IRS ERC Voluntary Disclosure Program provides a special resolution opportunity for employers with erroneous or excessive ERC claims. The IRS recognizes that many erroneous or excessive ERC claims are partly due to aggressive marketing

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AICPA Makes Useful Recommendations For International Forms 3520/3520

2 January, 2024

The American Institute of CPAs (AICPA) submitted comment letters to the IRS requesting improvements be made to two international tax returns pertaining to foreign trusts. The AICPA requested that the IRS update, add to, and

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New IRS Voluntary Disclosure Program lets employers who received questionable Employee Retention Credits pay them back

24 December, 2023

This week, the IRS announced a new ERC voluntary disclosure program (ERCVDP) that has many distinctive features: Our firm has filed hundreds of IRS voluntary disclosure submissions over the years, and there are numerous similarities

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Parag Patel Esq. Speaks at NJCPA Seminar on”Employee Retention Credit Audit Issues: Surviving IRS Scrutiny”

20 December, 2023

Parag Patel Esq. was a featured speaker at a New Jersey Society of Certified Public Accountants (NJCPA) Seminar entitled “Employee Retention Credit Audit Issues: Surviving IRS Scrutiny”. You may email our office to receive the

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The IRS’s First-Time Abatement (FTA) Penalty Waiver

19 December, 2023

There are currently more than 160 penalties contained in the US tax code. There is a penalty for nearly every possible reporting, filing, and payment requirement failure.  While penalties have long been a component of Federal

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Recent Posts

  • Is Turbotax Reliance a Valid Defense Against IRS Penalties?January 28, 2026
  • New Proposed IRS Voluntary Disclosure Practice (VDP): FAQsJanuary 20, 2026
  • Second Circuit Affirms Recklessness Standard for Willful FBAR PenaltiesJanuary 16, 2026
  • Top Tax Strategies for the 2026 LandscapeJanuary 8, 2026
  • Navigating the High Penaties of Delinquent Form 3520 FilingsJanuary 3, 2026

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